Delegated Approval Introduction of Emissions-Based Parking Permit Charges following Statutory Consultation August 2020

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Delegated Approval Introduction of Emissions-Based Parking Permit Charges following Statutory Consultation August 2020
The London Borough of Newham
                                                          Community & Environment

                  Delegated Approval
    Introduction of Emissions-Based Parking Permit
        Charges following Statutory Consultation
                      August 2020
1. Background
Parking policies and procedures have the ability to influence the number, type and the amount
of usage of vehicles in an area and can be an important tool in delivering behavioural change
and improvements to air quality (and consequently environmental and public health
improvement). Local authorities have powers to control and regulate parking.

In terms of the wider policy framework all London Councils must operate in accordance with:

       the statutory duties with respect to air quality set out in Part IV of the Environment Act
        1995;
       the requirements of the London Local Air Quality Management statutory process set
        by the GLA (Greater London Authority);
       The (London) Mayor’s Transport Strategy 2018;
       The (London) Mayor’s (draft) New London Plan;
       The national ‘Road to Zero’ Strategy which aims for 50%-70% of new car sales to be
        ultra-low emissions vehicles by 2030;
       The Clean Air Strategy 2019;
       The Newham Air Quality Action Plan.

Newham residents are exposed to high levels of toxic pollution caused by vehicles causing the
highest rate of deaths in England - that’s 96 people dying prematurely each year. Newham
also has the highest number of children admitted to hospital due to asthma-related conditions.

The Air Quality Action Plan has been produced as part of our legal duty to London’s Local Air
Quality Management strategy. It outlines the actions we will take to improve air quality in
Newham up to 2024.

Particulate Matter are particles that can be ingested deep into the lungs. Most particulate
matter emissions in London are caused by road traffic. The whole of Newham is significantly
exceeding the World Health Organisation’s air quality guideline objective. This pollutant has
significantly adverse health impacts, particularly for the most vulnerable in our society. As well
as contributing to the achievement of our air quality duty, the revised parking policies and scale
of charges must also meet the London Mayor’s Transport Policy outcomes as well as our local
policy and wider corporate aspirations.

The Cabinet approval in February 2020 agreed to the draft revised parking policies for the
second phase of informal public consultation which was carried out in March 2020. A total of
4,832 responses to the online questionnaire were received by the council of which 4,281 raised
concerns (mostly relating to costs) regarding the introduction of emissions-based permit
parking charges to help improve air quality in Newham, However it should be noted that this
only represents approximately 1.5% of the Newham population, and less than 8% of the

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Delegated Approval Introduction of Emissions-Based Parking Permit Charges following Statutory Consultation August 2020
vehicles registered within the borough meaning that the vast majority of residents or existing
permit holders did not raise any concerns or objections.

Historically, few motorists ever support the introduction of, or an increase in, parking charges
irrespective of the wider health benefits associated with the proposal or their general support
for environmental and health interventions. The lack of support is therefore more likely to be a
reaction to the potential of paying for a permit that is currently free, regardless of the fact the
vehicle may be higher polluting and it is not therefore considered to be a rejection of the
concept of, or need for introducing an emissions-based charging system.

Consequently, Delegated Authority in consultation with the Corporate Director and Cabinet
Member was obtained in June 2020 to proceed to a statutory consultation on the proposed
emissions-based permit charges (along with other permit changes), and this ran from 8th to
29th July 2020.

In total, only 199 responses were received from the statutory consultation, of which 166 were
objections, 19 were supportive, 7 provided additional comments only (but did not object), 7 felt
more information was required and 1 objection was in relation to the proposed 2 hour free
parking allocation. More details on the responses received are at Section 4 and Appendix A.

The objection responses received mimic, to some extent, those from the previous round of
consultation, in that there was the expected adverse reaction to the introduction of charges
when none currently apply, but without any alternative suggestions to address our air quality
crisis being offered. However, it is noted that the quantum of responses received is much lower
than that in the previous consultation round, suggesting that there is a growing acceptance of
the need for the measures and the outcomes they will deliver.

This report therefore seeks Delegated Approval to over-rule the objections received and
progress with the making of the supporting traffic order for the introduction of emissions-based
parking permit charges for both residential and business parking permits. The report also
seeks Delegated Approval to defer the introduction of the new charging regime until January
2021, so as to allow for a period of economic recovery and for residents to have adequate
advance notice of the new charges coming into effect. This delay will also allow for the systems
testing of the Council’s parking software which will manage the new permit system.

2. Recommendations
That the Assistant Director for Highways and Sustainable Transport, in close consultation and
agreement with the Corporate Director for Environment and Sustainable Transport, and the
Cabinet Member for Environment, Highways and Sustainable Transport, is recommended to:

       1.   Note and consider the objections and comments received and approve the officer
            responses as detailed in Appendix A;
       2.   Over-rule the objections as outlined in section 4 and in detail at Appendix A;
       3.   Approve the making of the relevant Traffic Management Order in October 2020
            under the relevant Sections of the Road Traffic Regulation Act 1984, as amended,
            in order to implement emissions-based parking charges and other permit changes
            as previously approved;
       4.   Approve the Statement of Reasons for the above;
       5.   Approve the deferral of the date on which the relevant TMO above comes into
            force until 6th January 2021.

3. Details

The key new change to the council’s Parking Policy and Procedures is the introduction of
resident and business permit charges based on the CO2 emissions category used by HMRC
for vehicle taxation purposes.

Vehicles are grouped into charging tiers according to HMRC grouping as shown in the tables
below:

                                                2
Engine
               CO2                 Newham
  HMRC                 Size (c.c.)
             emissions             Emission                    Example Car Models
  Band                    (Pre‐
              (g/km)                 Tier
                         2001)

     A            0         1‐600                   All battery electric vehicles eg Nissan Leaf, Tesla
                                                     models, BMW I models, VW e‐Golf, and some
                                           Tier 1    hybrids eg Passat Hybrid, Mercedes C/E 330e
     B         1 ‐ 50      601‐900                            models, Toyota Prius Plug in

     C         51 ‐ 75    901‐1000

                           1101‐                      Most hybrid models, eg Toyota Prius, Yaris &
     D         76 ‐ 90                               Auris, Range Rover PHEV and most small petrol
                            1200
                                           Tier 2   and diesel vehicles, eg Ford Fiesta, Focus (newer
                           1201‐                    models), Vauxhall Corsa, Astra, Kia Ceed, Peugot
     E        91 ‐ 100
                            1300                      308, Renault Megane, Clio, BMW 1 series etc.
                           1301‐
     F       101 ‐ 110
                            1399
                           1400‐
     G       111 ‐ 130
                            1500                       Audi A2,3,4 & 5, BMW 2, 3 4 series (smaller
                                                    engines), Ford Focus 2.0, Mondeo, Mercedes A,
                           1501‐
     H       131 ‐ 150                     Tier 3   C, E class (newer 180d, 200d and 220d models),
                            1650                      VW Golf, Jetta, Hyundai i30, Kona, Seat Leon,
                           1651‐                            Ibiza, Citroen C3, C4, Berlingo, etc
      I      151 ‐ 170
                            1850
                           1851‐                      BMW 2,3,4 series, X2,X3,X4,X5, VW Touareg,
      J      171 ‐ 190
                            2100                      Tiguain, Audi Q7, Q8, Porsche 911, Cayenne,
                                           Tier 4      Land Rover Range Rover & Discovery (sport
                           2101‐
     K       191 ‐ 225                                       models). Mercedes E350, GLC
                            2500
                           2501‐                    Jaguar FType V6, Jeep Wrangler 2.8, Mitsubishi
     L       226 ‐ 255
                            2750                    Shogun 3.2, Mercedes AMG 63 models, Bentley
                                           Tier 5    models, Rolls Royce models, Ferrari models,
                          2751 and
     M       Over 255                                              Maserati models
                           above
Residential Permit Emissions‐Based Tiers

                        Engine
                CO2
  HMRC                Size (c.c.)   Newham
            emissions
  Band                   (Pre‐    Emission Tier
              (g/km)
                        2001)
     A            0     1‐600
     B         1 ‐ 50  601‐900       Tier 1
     C        51 ‐ 75 901‐1000
                        1101‐
     D        76 ‐ 90
                         1200
                        1201‐
     E       91 ‐ 100
                         1300
                        1301‐
     F      101 ‐ 110
                         1399
                                     Tier 2
                        1400‐
     G      111 ‐ 130
                         1500
                        1501‐
     H      131 ‐ 150
                         1650
                        1651‐
     I      151 ‐ 170
                         1850
                        1851‐
     J      171 ‐ 190
                         2100
                                     Tier 3
                        2101‐
     K      191 ‐ 225
                         2500
                        2501‐
     L      226 ‐ 255
                         2750
                                     Tier 4
                      2751 and
    M       Over 255
                        above
Business Permit Emissions‐Based Tiers

Following the earlier consultation phases set out in Section 1, and the Cabinet approval
obtained in February 2020, a Delegated Authority report recommending to progress with a
statutory consultation on the emissions-based permit charges was prepared and approved in
June 2020. This outcome of this consultation is discussed below in Section 4.

                                                                     3
4. Consultation to date
         First phase consultation completed in March 2019 (Assembly events and on-line
          engagement via POL.iS platform);
         Cabinet Member engagement was undertaken prior to Cabinet approval in February
          2020;
         Second stage consultation completed in March 2020 (on-line questionnaire);
         The Cabinet Member for Environment, Highways and Sustainable Transport has been
          fully engaged throughout the entire parking policies and procedures review process;
         Statutory Consultation (July 2020)

The statutory consultation for the introduction of emissions-based parking permit charges was
carried out between 8th and 29th July 2020.

The council received 199 responses and these are summarised in the table below:

                                      Emissions Based Consultation Objection Type Summary

                                                                                                             No
                                                                       Objection to 2                        Objection
                                                                                                   More info
                                                        Objection to   hour free                             made ‐
                                                                                                   Required
First Permit   First Permit Charge & Other Objection    permit issue   parking                               Comments Total
Charge         Generic info email    including cost     process        allocation       In Support           only      Responses
        41               61                    63             1                1             19       7           7       200
                                   Total ‐ Objections
                                           167

Out of 199 responses received all of the objections included concerns about costs associated
with the implementation of emissions-based permit charges.

         41 of the responses objected solely to the fact there is likely to be a charge for the
          first resident permit per household;
         61 objected to the fact there is likely to be a charge for the first resident permit per
          household but raised other concerns relating to air quality and timescales for
          implementation;
         63 responses were objecting to introduction of emissions-based permit charges and
          a high number were also raising concerns about the costs associated with these
          charges during the current economic crisis with job losses and Covid-19;
         1 objection was raised in relation to the 2 hour free parking allocation, and
         19 responses were in full support of the proposals.

The remaining 14 responses did not object to the proposals but either required more
information or made comments in relation to other parking matters which are not relevant to
this report and will be addressed separately.

Generally, those 41 objectors that simply objected to a charge being levied could have been
expected, and there was no acknowledgement of any need to address air quality by other
means in their responses, and they were purely financial in nature. Given the modest charges
to be introduced, and that the majority of Newham residents do not own private cars, these
objections can be over-ruled.

Of the 61 objecting to the charges but also to the relevance to air quality and timescales, these
respondents tended to dismiss air quality as a valid argument for the introduction of revised
charges. This is quite a concern, as the Borough has particularly poor air quality and public
health as a result, and this is clearly not well understood – or simply is denied for convenience.
Either way, our air quality issues are irrefutable and objections that dismissed the relevance of
charges to air quality can be over-ruled. In this group a number also expressed concerns
about timing of the measures, which we believe have been addressed by the deferral of the
measures until 2021. Therefore, these concerns have been addressed and these too can be
over-ruled.

                                                               4
65 responses cited the Covid 19 crisis as a reason not to progress – due to economic impacts,
job losses etc. While we acknowledge that Newham residents have taken a financial impact
from Covid, it is very clear from Public Health England data that we have taken a heavy impact
on health, with one of the highest mortality rates in London – which is directly related to the
respiratory health of our residents, which in turn is as a result of our air quality. We must
prioritise the health of our residents and also improve our resilience to any further outbreak, so
in our view Covid has made emission based charges even more of an imperative. For this
reason, these objections can also be over-ruled.

Therefore, following close consideration of the objections received, and the requirement to
achieve corporate objectives of improved air quality, health and wellbeing, it is recommended
the objections be over-ruled and the Traffic Management Order supporting the introduction of
emissions-based parking permit charges progressed with immediate effect.

Details of the objections raised in relation to the implementation of emissions-based permit
charges are provided along with the detailed officers responses to each are both contained in
Appendix A. (For brevity, responses have been grouped by objection type, so not all 166
responses have been provided with an individual response.

The Statement of Reasons for the making of the order is attached at Appendix B

5. Forward Programme
No further approvals beyond this Delegated Authority are required to implement the emission
based parking charges as set out in the report to Cabinet in February 2019.

While the traffic order can effectively now be made, the date when it will come into force will
be deferred until 6th January 2021, to allow for a period of economic recovery.

Announcement of this decision and the date of introduction of the new charges will be a political
decision and require appropriate timing.

6. Financial Implications
The financial implications of emissions-based charging on parking revenues is set out in full in
the February Cabinet paper. However, to summarise, the Council’s Parking service currently
generates income of around £24m per annum, of which £5m relates to income from the issue
of around 190,000 parking permits for residents, businesses, visitors, staff and carers.
Approximately 57,000 of these are residents’ permits and 2,500 business permits. Expenditure
incurred in the operation of the service is around £10m per annum, leaving a surplus of
approximately £14m per annum, which supports the maintenance of roads, the provision of
school crossing patrols, community transport and assisted travel schemes, such as the
Taxicard scheme and Freedom Pass. (Newham’s contribution to London Councils for the
London-wide Freedom Pass costs exceed £10m every year.)

The Road Traffic Regulation Act 1984 states that local authorities can only spend surplus
parking income on traffic and transport measures. However, the Greater London Authority Act
1999 amended this legislation. It enables London local authorities to use any surplus parking
income to implement the Mayor of London’s Transport Strategy. The Transport Strategy states
that parking surpluses can be used to fund:

         Bus priority measures and other measures to improve bus services
         Structural maintenance of bridges and roads
         Healthy Streets areas identified in the Local Implementation Plan
         Environmental street improvement schemes
         Interchange projects
         Measures to assist freight developed through Freight Quality Partnerships
         Complementing congestion charging
         Development of school travel plans and workplace travel plans

                                                5
 Vehicle emissions monitoring and enforcement.

The proposal to introduce emissions-based permit charges for residents and businesses could
generate an additional £4.5m in year one on current levels, based on charges according to
emissions tiers, as set out in the tables in section 3, with residents’ vehicles with emissions of
50g/km or less receiving no charge for a permit (75g/km or less for business permits). The
estimated income is based on vehicle type data from DVLA and permit data. However as the
vehicle fleet is influenced by the charges it is expected to reduce steadily through years two
and three.

The introduction of the new permit charges in January 2020, with an ongoing extension of
current permits which expire in the intervening period between April 2020 and that date, will
ensure full permit income is achieved in 2020/21 under the new charging regime.

Environmental and financial outcomes will be monitored annually, and the charging regime will
be reviewed accordingly.

7. Legal Implications
The Traffic Management Act 2004 and the Statutory Guidance that accompanies it requires
local authorities to regularly review their policies and procedures to ensure they remain fit for
purpose. The Environment Act 1995 and other national, London-based and local policies
require the council to improve air quality for all its residents. The new parking policies and
procedures include measures designed to affect vehicle use and encourage a shift to less
polluting forms of transport.

The council has the power to introduce such measures under the Road Traffic Regulation Act
1984, as amended, and the procedure for doing so is set out in the Local Authorities’ Traffic
Orders (Procedure) (England and Wales) Regulations 1996.

The traffic order required to revise parking permits and charges will be processed under
sections 45, 46, 49 and 124 of the Road Traffic Regulation Act 1984.

The procedure regulations requires the council to notify the objectors within two weeks of the
making of the order.

                                                6
8. Approvals
Report Originator                   Murray
                                    Woodburn        Signed:                    Dated:

                                                    Murray Woodburn          11.08.2020

Principal Officer, Parking Design   Diane Bourne    Signed:                    Dated:
                                                                             11.08.2020

Principal Officer, Traffic Orders   Neil Barker     Signed:                    Dated:
                                                                             11.08.2020

   I approve the above recommendation:

Assistant Director (Highways and    Mario           Signed:                    Dated:
Sustainable Transport)              Lecordier

                                                                              12.10.20

Corporate Director, Environment     Jamie Blake     Signed:                    Dated:
and Sustainable Transport                                                    12.10.2020

   I confirm I have been fully consulted upon and approve the above recommendations:

Cabinet Member for Environment,     Councillor                                 Dated:
Highways and Sustainable            James Asser
Transport                                                                     13.10.20

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Appendix A

Details of Objections Received and Officer Responses:

                                       Appendix A
                          Officer Responses to Objections Raised:

The statutory consultation for emissions‐based parking permit charges was carried out between 8th
and 29th July 2020 and has resulted in 200 responses of which 167 were objections and these are
detailed in this report.

The council received:

       61 duplicate responses in relation to the first permit charge, emissions and parking revenue
        and are detailed along with the officer response in A.1 below;
       42 responses from members of the public objecting to the introduction of the first permit
        charge and the officer response is detailed in A.2 below;
       2 responses were received objecting to the first permit charge and raising concerns for Blue
        Badge Holders, elderly and people with young families and the officer response is detailed in
        A3 below;
       3 responses were received from members of the public objecting to the length of 2 Hours “all
        day” free parking allocation and the officer response is detailed in A4 below;
       23 responses were received from members of the public objecting primarily to the cost of the
        permit charge when Covid‐19 is affecting many residents and the officer response is detailed
        in A5 below;
       25 responses were received from members of the public objecting the cost to residents if the
        introduction of emissions‐based parking permit charges is implemented and the officer
        response is detailed in A6 below;
       9 responses were received from members of the public objecting to the proposals in some
        other way and an officer response is detailed below in A7;
       1 response was received in relation to the operational process for permit issue; and
       A number of other responses were received from members of the public where no details of
        were provided as to the reason the objection was made and an officer response to these is
        detailed below in A8.

A.1 Objections Relating to Charges, Taxation, Revenue Generation:
1. I would like to object to implementation of the charge for parking a vehicle near to my home. This
is something that the Council promised not to implement when they consulted and implemented the
CPZ in the borough. Many residents including myself are reliant on a vehicle for many reasons
(supporting disabled family members, work) Vehicles are substantial purchases that come with
additional costs (insurance, mot, maintenance), upgrading to more economical vehicle at such notice
puts me and family under considerable financial strain, when we are already very pressured and
stressed. Unfortunately the previous consultation on parking has been flawed. Consultation has been
via information within the Newham Council website. This has resulted in most residents being unaware
of the consultation, which seriously reduces their ability to respond to it. This I believe warrants both
consultations as unfair.
2. 89% of respondents objected to the charge when consulted in March 2020. This demonstrates that
there was no appetite for this then and I believe that there is still none. I certainly do not want to see
this charge implemented. As the Mayor wants ‘a beacon of participatory democracy’, the people’s
voice should be heard and taken on board.

3. TFL will extend its ULEZ scheme in 2021 which will tax heavier polluting vehicles. Surely LBN should
wait and see the effects of this policy before double taxing its residents.

                                                    8
4. There is a high volume of residents who use their vehicle for work purposes and for these residents
a charge will no influence their car usage behaviour as they feel they have no option. This will have no
significant change on air quality.

5. When Newham Council implement the restrictions on parking, they promised residents that the first
vehicle would be free. Therefore, this would be a breach of this promise.

6. To suggest that non‐car owners shouldn't subsidise car owners is short sighted. We live in an
economy dominated by the transport of goods and services by road vehicles. Just because you may
not own a vehicle does not mean that you aren't contributing to air pollution everyday by simply
existing and buying goods and services.

7. The Council generates a substantial amount of revenue from parking contraventions etc. The cost
of administering the scheme is minimal in comparison, and therefore the argument to charge for cars
(including breaking a promise and charging for the first car) does not stand. Therefore, this does not
justify charging cars.

8. The issue of air pollution is massive and it can't be ignored. I think a tax on cars dependant on
emissions, is only fair under the following circumstances:

(a) Residents should be given the time and the opportunity to transition to using more economical
vehicles. Implementing such a scheme with such notice places immense pressure on residents. Many
of us do not have the resources, time or the money to make such a substantial change at such short
notice.

(b)Allowing residents the time to transition, provides the Council the opportunity and time to prepare
for this transition. (E.g. implementing charging points, implementing renewable energy creation in the
majority of buildings) At the current moment the borough is not in a position to support the majority
of residents switching to electric cars.

9. If LBN really wants to cut emissions, force the parking inspectors to use pedal cycles rather internal
combustion motorcycles.

10. The suggested relaxation of the current type of towing policy is fully supported.

I agree that there are probably many vehicle trips made in Newham that could be made by cleaner
methods. However I believe the vast majority of journeys are made by people trying to make a living
and feed their family. To make the proposed changes soon is grossly unfair. However I would support
this policy if the conditions I make in point 8 are met. I encourage you all to reject this proposal.

Officers Response: The Road Traffic Regulation Act 1984 (RTRA) as amended places a duty on the
council to secure the expeditious, convenient, and safe movement of vehicular and other traffic
(including pedestrians), to provide suitable and adequate parking facilities on and off the highway
and to provide an attractive street environment for everyone and the implementation of residential
parking zones borough wide has proven to be an effective way to achieve this.

Newham residents are however exposed to high levels of toxic pollution caused by vehicles resulting
in the highest rate of deaths in England which equates to ninety six people dying prematurely each
year. Newham also has the highest number of children admitted to hospital due to asthma‐related
conditions.

In response to the above concerns which not only affects residents living in the borough of Newham
but is both a London and global issue and in advance of the proposed extension to ULEZ which is
central to the Mayor’s plans to improve the health of Londoners by cleaning up the city’s toxic air,
which leads to the early deaths of thousands of Londoners every year; an Air Quality Action Plan has
been produced as part of the council’s legal duty to London’s Local Air Quality Management strategy.
It outlines the actions we will take to improve air quality in Newham up to 2024 and aims to
incentivise motorists to make more environmentally friendly choices which in turn will improve air
quality.

                                                   9
In line with the strategy and as part of the Mayor of London’s Go Ultra Low City Scheme the council
has already installed some electric car chargers in the borough and will be installing a further 40
double electric car chargers on nominated residential roads during 2020/21. In addition to this the
council is applying for further funding to expand the network of electric chargers throughout the
borough.

The council has also invested in a network of air quality monitors for NOx and Particulate Matter
(PM10) and third party monitoring for locations such as London City Airport for which constant
monitoring will remain a priority.

Within Residential Parking Zones (RPZs) residents can apply for a permit which entitles them to park
within permit holder bays at any time during the controlled hours of their zone without time limit.
Whilst granting a permit allows the use of a space in an RPZ, there is no entitlement to or guarantee
of a specific space within the zone. However, by discouraging certain groups of non‐residents from
parking in an area, an RPZ increases the likelihood that a resident can park close to their home and
helps to encourage, via the use of emissions‐based charges, consideration for vehicle usage and type
change.

In 2012 it was agreed the first resident permit per household would remain free of charge but with
growing concerns surrounding climate change and air quality there is a need to incentivise motorists
to make improvements to air quality. The council’s residential parking zones had been implemented
at a time when emissions‐based permit charging was in its infancy. Subsequently many London
boroughs have introduced some form of emission‐based permit charging and are finding this to be
an effective tool in reducing vehicle emissions by influencing behavioural change and to help improve
air quality. The proposed introduction of emission‐based parking permit charges is therefore similar
to those already operating in many London boroughs.

The council has undertaken two distinct public engagement phases; the first in the spring of 2019
and the second in March 2020. The initial phase consultation results showed two‐thirds of residents
wanted measures adopted to improve air quality and reduce car use however the second
consultation did not indicate such a clear majority for the implementation of an increase in emission‐
based parking permit charges.

An analysis and evaluation of the positive and negative impacts from the new charges concluded
that the reasons for introducing emission‐based parking charges outweigh the reasons for not
implementing them.

The council has considered the concerns that may arise from the proposed introduction of emissions‐
based parking permit charges when the economy is suffering due to the outbreak of Covid‐19 and it
is for this reason the implementation of these proposals would not be introduced until January 2021,
which would enable residents / businesses additional time to make alternative travel arrangements.

It is therefore recommended the objections be over‐ruled and the introduction of emissions based
parking permit charges be progressed.

A.2 Objection to Charge for First Permit:
The council received responses from members of the public whose only objection was to the
introduction of a charge for the first resident parking permit.

Officers Response: The Road Traffic Regulation Act 1984 (RTRA) as amended places a duty on the
council to secure the expeditious, convenient, and safe movement of vehicular and other traffic
(including pedestrians), to provide suitable and adequate parking facilities on and off the highway
and to provide an attractive street environment for everyone and the implementation of residential
parking zones borough wide has proven to be an effective way to achieve this.

Newham residents are however exposed to high levels of toxic pollution caused by vehicles resulting
in the highest rate of deaths in England which equates to ninety six people dying prematurely each

                                                 10
year. Newham also has the highest number of children admitted to hospital due to asthma‐related
conditions.

In response to the above concerns which not only affects residents living in the borough of Newham
but is both a London and global issue and in advance of the proposed extension to ULEZ which is
central to the Mayor’s plans to improve the health of Londoners by cleaning up the city’s toxic air,
which leads to the early deaths of thousands of Londoners every year; an Air Quality Action Plan has
been produced as part of the council’s legal duty to London’s Local Air Quality Management strategy.
It outlines the actions we will take to improve air quality in Newham up to 2024 and aims to
incentivise motorists to make more environmentally friendly choices which in turn will improve air
quality.

In line with the strategy it is proposed that new banded charges for resident and business parking
permits will be introduced based on a vehicle’s CO2 emissions. Resident permits for those with the
least polluting vehicles will remain free, while those with more polluting vehicles will pay
progressively more.

It is therefore recommended the objections be over‐ruled and the introduction of emissions based
parking permit charges be progressed.

A.3 Objection to First Permit and Blue Badge Holder Concerns:
I strongly object to the proposed changes to the resident parking charges for 1st cars. As a disabled
driver myself. I object on the grounds that there are other Blue‐Badge holders in the Borough and
elderly couples and lots of families. We have all suffered during lockdown in one form or another
financially and personally.

Officers Response: The Road Traffic Regulation Act 1984 (RTRA) as amended places a duty on the
council to secure the expeditious, convenient, and safe movement of vehicular and other traffic
(including pedestrians), to provide suitable and adequate parking facilities on and off the highway
and to provide an attractive street environment for everyone and the implementation of residential
parking zones borough wide has proven to be an effective way to achieve this.

Newham residents are however exposed to high levels of toxic pollution caused by vehicles resulting
in the highest rate of deaths in England which equates to ninety six people dying prematurely each
year. Newham also has the highest number of children admitted to hospital due to asthma‐related
conditions.

In response to the above concerns which not only affects residents living in the borough of Newham
but is both a London and global issue and in advance of the proposed extension to ULEZ which is
central to the Mayor’s plans to improve the health of Londoners by cleaning up the city’s toxic air,
which leads to the early deaths of thousands of Londoners every year; an Air Quality Action Plan has
been produced as part of the council’s legal duty to London’s Local Air Quality Management strategy.
It outlines the actions we will take to improve air quality in Newham up to 2024 and aims to
incentivise motorists to make more environmentally friendly choices which in turn will improve air
quality.

In line with the strategy it is proposed that new banded charges for resident and business parking
permits will be introduced based on a vehicle’s CO2 emissions. Resident permits for those with the
least polluting vehicles will remain free, while those with more polluting vehicles will pay
progressively more.

The council has considered the concerns that may arise from the proposed introduction of emissions‐
based parking permit charges when the economy is suffering due to the outbreak of Covid‐19 and it
is for this reason the implementation of these proposals would not be introduced until January 2021,
which would enable residents / businesses additional time to make alternative travel arrangements.

                                                 11
A.4 2 Objections to Hours “all day” free parking allocation:
It is pleasing to see that Newham is trying to do more to improve the air quality within the borough.
Whilst this is welcomed it is a shame that little thought has been given to prompt residents shopping
more in local high streets; using local businesses and services. The current mini zones do very little to
encourage local residents to shop locally rather than going to large supermarkets or shopping centres
due to having to pay to park outside of their mini zones. The proposal of giving each household 2 hours
a month parking allocation outside of their zone simply does not go far enough. This is not practical,
extremely limiting and poorly thought through. For example if an individual has to park to attend an
appointment i.e. to see their GP then their entire months allocation is gone on attending a single
appointment. What about being able to do other things in the borough i.e. do weekly shop. Other
boroughs such as Tower Hamlets which is more inner London do more to support residential parking
across their borough so why can't Newham?

As a resident I have always found the mini zones to be very restricting and also feel that they do not
bring the community together within the borough. I urge for you to reconsider and redraft point (v) on
the draft proposal on the allocation of parking time outside of the mini zones per household.

Officers Response: Newham currently has 31 Residential Parking Zones (RPZs) and 5 Industrial
Parking Zones (IPZs) covering the entire borough. These were introduced over a number of years to
tackle some of the issues below.

       Increasing car ownership, resulting in pressure on residential roads particularly by
        commuters.
     Key venues, which were placing great demands on the network, including West Ham United
        Football Club and the ExCel Centre.
     High levels of parking stress near shops and restaurants, education sites, places of worship,
        schools, hospitals or rail, tube or DLR stations and businesses located away from residential
        areas and
     Pressure from developments including Westfield and the Queen Elizabeth Olympic Park and
        new residential developments
RPZs are considered nationally to be an effective way to manage the local roads in order to address
issues such as traffic/parking congestion, access, safety and car borne pollution, however it is
understood requirements change over time and as such the council endeavours to undertake reviews
to amend zone times and boundaries where concerns have been raised.

Newham offers short‐term, on‐street parking which ranges from a maximum stay of 30 minutes to
4 hours, usually in the form of either paid‐for parking bays in certain RPZs or free bays. These bays
have been implemented for people visiting shops, religious establishments and businesses and the
proposed introduction of the ‘all day’ permit is therefore intended to be in addition to the above
parking arrangements.

Newham residents are however exposed to high levels of toxic pollution caused by vehicles resulting
in the highest rate of deaths in England which equates to ninety six people dying prematurely each
year. Newham also has the highest number of children admitted to hospital due to asthma‐related
conditions. The council must therefore look at the needs of all of the residents and businesses within
the borough to support the Mayor’s Transport Strategy for improvements to air quality and
encourage modal shift from journeys by car to public transport.

It is for the above reasons the proposal for the 2 hours “all day” free parking allocation will not be
amended at this stage but will be considered again in line with government requirements to
regularly review the councils’ parking policies. It is therefore recommended the objections be over‐
ruled and the introduction of emissions based parking permit charges be progressed.

                                                   12
A.5 Introduction of emissions‐based parking permit charges during
Covid‐19:
R Ahmed ‐ I believe it the proposal to increase parking charges and parking permit cost is unnecessary
as Transport for London is already implementing ULEZ to make London cleaner, this will affect Newham
residents.

Newham Council increasing charges for what is an alleged attempt to get rid of old polluting vehicles
is a clear attempt to increase revenue in one of London’s poorest boroughs who has been hit the
hardest in this pandemic.

This proposal is poorly timed when lots of Newham residents have lost jobs and need the support of
the council at this time.

Officers response: The Road Traffic Regulation Act 1984 (RTRA) as amended places a duty on the
council to secure the expeditious, convenient, and safe movement of vehicular and other traffic
(including pedestrians), to provide suitable and adequate parking facilities on and off the highway
and to provide an attractive street environment for everyone and the implementation of residential
parking zones borough wide has proven to be an effective way to achieve this.

Newham residents are however exposed to high levels of toxic pollution caused by vehicles resulting
in the highest rate of deaths in England which equates to ninety six people dying prematurely each
year. Newham also has the highest number of children admitted to hospital due to asthma‐related
conditions.

In response to the above concerns which not only affects residents living in the borough of Newham
but is both a London and global issue and in advance of the proposed extension to ULEZ which is
central to the Mayor’s plans to improve the health of Londoners by cleaning up the city’s toxic air,
which leads to the early deaths of thousands of Londoners every year; an Air Quality Action Plan has
been produced as part of the council’s legal duty to London’s Local Air Quality Management strategy.
It outlines the actions we will take to improve air quality in Newham up to 2024 and aims to
incentivise motorists to make more environmentally friendly choices which in turn will improve air
quality.

In line with the strategy it is proposed that new banded charges for resident and business parking
permits will be introduced based on a vehicle’s CO2 emissions. Resident permits for those with the
least polluting vehicles will remain free, while those with more polluting vehicles will pay
progressively more.

The council has considered the concerns that may arise from the proposed introduction of emissions‐
based parking permit charges when the economy is suffering due to the outbreak of Covid‐19 and
has agreed to defer the introduction of the new charging regime until January 2020, so as to allow
for a period of economic recovery and for residents to have adequate advance notice of the new
charges coming into effect.

It is therefore recommended the objections be over‐ruled and the introduction of emissions based
parking permit charges be progressed.

Samiha Begum, Thanjima Hussain, Teodora Paduret, Nadia Hague and Shuhel Uddin Kahleda
Kahnom Fateha Khanom . All state ‐ I highly object to the proposed emissions based vehicle charging
bands because simply put ‐ most of us in Newham cannot afford it. This is tone deaf to the needs of
the constituents as one of the most impoverished boroughs in London.

With all the job losses that will be inevitable in the coming weeks and months, I believe that Newham
residents should not be put under further financial strain. Our economy is tanking and this is an
additional financial burden.

                                                 13
Please put yourselves in our shoes and do the right thing. If anything, the current parking charges I feel
are exorbitant and above inflation and agnostic of the economic situation we have right now.

Newham residents are exposed to high levels of toxic pollution caused by vehicles resulting in the
highest rate of deaths in England which equates to ninety six people dying prematurely each year.
Newham also has the highest number of children admitted to hospital due to asthma‐related
conditions.

The National Clean Air Strategy 2019 devolves responsibility for further reducing emissions mainly
to a local level. The national targets, such as the aim of 50‐70% of new car sales being Ultra Low
Emissions Vehicles (ULEV) by 2030, require local authorities to develop the enabling support
infrastructure.

The London Mayor’s regional proposal to extend the ULEZ from central London out to the North and
South Circular Roads in October 2021 will also require local actions on the part of those Boroughs
that will be affected.

The council has considered the concerns that may arise from the proposed introduction of emissions‐
based parking permit charges when the economy is suffering due to the outbreak of Covid‐19 and
has agreed to defer the introduction of the new charging regime until January 2020, so as to allow
for a period of economic recovery and for residents to have adequate advance notice of the new
charges coming into effect.

It is therefore recommended the objections be over‐ruled and the introduction of emissions based
parking permit charges be progressed.

Linda Blanchard ‐ I object to the proposal to levy a charge for all except electric vehicles. The problem
as I see it is that there are very few electric charging points around the Borough. Indeed, the only one
I know of in Stratford where I live is outside a public house in Tramway Avenue, where it seems to be
monopolised by one car owner. I feel that until drivers can have greater access to charging points, it is
unfair to penalise them for not having electric cars. I would buy an electric car tomorrow if I could have
regular access to a charging point. Like many Newham residents, I live in a street of terraced houses
which would make the installation of suitable charging points impossible.

Whilst I admit to owning a car with a petrol engine, I would like to point out that I clock up very few
miles within the Borough. Most of my journeys around Newham are on public transport (which is
woefully inadequate). A few times a year I use my vehicle to travel to Milton Keynes to visit the graves
of my parents, as there is no other way I could make this journey. When I shop in the Borough, I use
my trusty "trolley" to transport my supplies. I object therefore to paying to house my car in Newham
because my car journeys do not contribute a great deal to the air pollution in the Borough.

I feel a better way to tackle air pollution in Newham would be to work with TfL to improve the public
transport system around the Borough. Until there is a reliable, adequate, bus service in Newham,
residents will continue to use their cars, especially at times such as these when bus capacity is
restricted because of the Covid‐19 Emergency.

It is my view that this charge is being introduced primarily as a much‐needed source of revenue in a
cash‐strapped borough such as ours, rather than the stated aim of reducing air pollution.

I ask that you take into account the above objections I have raised to the proposed parking scheme. I
am assuming that no final decisions have been made regarding the proposals and that if enough
objections are received there will be a further consultation to canvass the views of Newham residents.

Vicky Cook ‐ I object to the introduction of charging Newham Residents for cars that give off emissions.
This is a personal attack on those that are already vulnerable and low income families. Since COVID‐
19, there are even more families struggling with day to day finances and this is just another nail in the
coffin for those of us who rely on our cars. It is abhorrent that you think it is ok to charge when there
are already charges for this in central London. People also rely on getting the first permit for free and

                                                   14
not everyone can afford to change their car (I don’t know anyone who has £15k stashed to buy a new
car). This should not go ahead.

Officer Response: Newham residents are exposed to high levels of toxic pollution caused by vehicles
resulting in the highest rate of deaths in England which equates to ninety six people dying
prematurely each year. Newham also has the highest number of children admitted to hospital due
to asthma‐related conditions.

In line with the strategy it is proposed that new banded charges for resident and business parking
permits will be introduced based on a vehicle’s CO2 emissions. Resident permits for those with the
least polluting vehicles will remain free, while those with more polluting vehicles will pay
progressively more.

The council has considered the concerns that may arise from the proposed introduction of emissions‐
based parking permit charges when the economy is suffering due to the outbreak of Covid‐19 and
has agreed to defer the introduction of the new charging regime until January 2020, so as to allow
for a period of economic recovery and for residents to have adequate advance notice of the new
charges coming into effect.

It is therefore recommended the objections be over‐ruled and the introduction of emissions based
parking permit charges be progressed.

M Fabikun ‐ I am read the proposed changes and I highly object to them strongly, during this time of
coronavirus and a possible recession, its beyond belief that a labour borough is still pushing policies
that are punishing drivers. These new policies will punish homes with more than one car, without
considering that people are struggling as it is. Who will pay for the charges when there is a greater
concern about getting to work safely and paying for food? There is concern for the environment but
yet there should be a common sense approach to this and its timing. These kinds of policies would see
typical labour voters like myself seriously consider voting for another party due to these hard hearted
policies during the time of a national crisis and pandemic.

Officer Response: The council has considered the concerns that may arise from the proposed
introduction of emissions‐based parking permit charges when the economy is suffering due to the
outbreak of Covid‐19 and has agreed to defer the introduction of the new charging regime until
January 2020, so as to allow for a period of economic recovery and for residents to have adequate
advance notice of the new charges coming into effect.

It is therefore recommended the objections be over‐ruled and the introduction of emissions based
parking permit charges be progressed.

Tee Fabikan ‐ I feel it is not a good time to do this because:
1. A lot of people list their jobs due to Covid 19.
2. In order to keep self‐alive, a number of people stopped using public transport and started to drive.
3. A number of people are afraid of catching Covid 19 so can only go out in private vehicles.

Officer Response: The council has considered the concerns that may arise from the proposed
introduction of emissions‐based parking permit charges when the economy is suffering due to the
outbreak of Covid‐19 and has agreed to defer the introduction of the new charging regime until
January 2020, so as to allow for a period of economic recovery and for residents to have adequate
advance notice of the new charges coming into effect.

It is therefore recommended the objections be over‐ruled and the introduction of emissions based
parking permit charges be progressed.

Ian Gibson and Agnes Viv state ‐ Newham’s proposed parking policy is not tackling the real issues
related to driving and pollution in Newham. Specifically:

                                                  15
1. Having a virtual system of parking permits is not good. This has not worked for the car tax disc system
and it will not work for Newham parking. It will be impossible for a passer‐by, neighbour or resident to
tell if a car is correctly parked.
2. Frequent idling of cars by those using recreational drugs in Newham parking spaces. This occurs both
during the restricted period during the day and also at night when parking is not restricted. The cars
are not actually treated as being “parked” as the occupants simply sit there, engine idling, and drive
off if approached. Newham needs to enforce its current parking plan.
3. The criteria for applying for a parking permit have not been made clear.
4. Extra charge on diesel cars is not reasonable or justified. These cars are the ones that need to be
parked so they should have discounted parking charge.
4. Driving in Newham, and therefore is for many, essential as the alternatives are not available or not
safe. In detail:
4a. it is often not possible to get on the DLR and TfL trains in normal hours.
4 b Driving is the only option to travel with The COVID pandemic, for safety, or no capacity on public
transport. Walking and cycling to work is not possible for many people
4 c there is no Santander type cycle scheme in the borough.
4 d Bicycle parking is inadequate.
4 e Frequent speeding by commercial vehicles and loose debris falling out are dangerous and a hazard
to all, especially pedestrians and cyclists.
5. driving to schools should be discouraged.
6. More expensive permits will exacerbate the abuse or private parking.
7. Issuing virtual parking permits will encourage fraud and encourage on‐selling of visitor permits. How
will the borough prevent somebody from applying at a different address they live at? How will this be
policed? The rightful resident cannot be paying a surcharge of £100 on top of the parking permit costs
because someone applied first at his/her address before.
8. New categories of permits is not required, e.g. Charities should not be allocated parking permits
different than business ones.
9. I do not understand how industrial permits should be more expensive than business permits. They
should at the minimum be the same as they are more polluting.
10. The borough should look at blocking the London City airport extension and the Gazeley freight
handling facility in the former Peruvian wharf in E16. This will have so much more impact on pollution
than the proposed new parking scheme.

Officer Response: A virtual permit system enables CEOs to monitor permit issue for vehicles using a
hand held device. If a vehicle is found to be parked without a valid LBN permit or without making
the required payment a PCN will be issued for the relevant offence.

The application process for the virtual permit system is being undertaken by the Parking Enforcement
team and they will ensure residents and businesses have sufficient notice of how to apply before the
proposed implementation date.

In line with the strategy it is proposed that new banded charges for resident, business parking
permits including Industrial Parking Permits will be introduced based on a vehicle’s CO2 emissions.
Resident permits for those with the least polluting vehicles will remain free, while those with more
polluting vehicles will pay progressively more.

The council can also advise there are proposals in place to introduce a bike scheme to enable
residents to hire bikes, Healthy School Streets schemes to restrict access to vehicles at start and finish
times outside of schools and a reduced rate business permit for Newham based charities who require
the use of a vehicle to undertake visits to premises (other than their registered charity address)
within the borough.

The council has also invested in a network of air quality monitors for NOx and Particulate Matter
(PM10) and third party monitoring for locations such as London City Airport for which constant
monitoring will remain a priority.

                                                   16
The council has considered the concerns that may arise from the proposed introduction of emissions‐
based parking permit charges when the economy is suffering due to the outbreak of Covid‐19 and
has agreed to defer the introduction of the new charging regime until January 2020, so as to allow
for a period of economic recovery and for residents to have adequate advance notice of the new
charges coming into effect.

It is therefore recommended the objections be over‐ruled and the introduction of emissions based
parking permit charges be progressed.

Syed Ismail ‐ I strongly reject the proposal as we can’t afford to buy hybrid or plugin cars. During this
pandemic rather than introducing the parking charges free for low income / no job residents. I am
afraid council is trying to rip off the affected residents. Most of the people are on low paid jobs and
Newham got more destitute people as compared to other boroughs. Same time, Thames water started
charging 5 times more by putting metered bill on the residents. May be I can afford the parking charges
(not the electric car) by sacrificing other things for the kids. But, I know most of the people in my
neighbours can’t afford buying hybrid cars. Please emphasise the government to help buying a hybrid
/ electric car.

Officer Response: The council has considered the concerns that may arise from the proposed
introduction of emissions‐based parking permit charges when the economy is suffering due to the
outbreak of Covid‐19 and has agreed to defer the introduction of the new charging regime until
January 2020, so as to allow for a period of economic recovery and for residents to have adequate
advance notice of the new charges coming into effect.

It is therefore recommended the objections be over‐ruled and the introduction of emissions based
parking permit charges be progressed.

Kiftzbro ‐ Good thinking Sherlock whilst half the borough is furloughed or made redundant and
struggling to pay rent, you now want them to pay extra £200 for parking permits

Dawn Skeritt ‐ Being one of the only boroughs that doesn’t charge a parking tax for first cars shouldn’t
be your reason for doing so. Trying to use the climate argument is condescending and a pile of tosh.
Why start with your residents who can least afford such an expensive change such as upgrading to an
electric car. What about buses? What about lorries?

I’m so scared this so called labour borough is slowly going to start pricing their poorest residents out
of London. Most of us have our adult kids at home with us as they can’t afford to rent privately or buy.
Forget the council housing list.

Things like an additional charge being brought in at such short notice impacts the entire household
especially if another adult in the home has to drive. This at a time when we are struggling to overcome
the impact of COVID‐19 on our friends, relatives and neighbours, Newham being the worst affected in
terms of infection and death. Some residents have already lost jobs and many others are uncertain if
they will have one soon regardless of the easing of lockdown.

Saeed Patel ‐ Whilst I appreciate the purpose of this change what I seem to find difficult to understand
is how the members of the Newham Council board can come up with a solution such as this. As you
well know many of the residents are of extremely low income. Partly why many houses in Newham
are overfilled with 15‐20 people residing in one property just so rent can be split and to be able to
afford rent. To be sanctioning these new proposals how do you expect residents of low income pay
these additional charges? Yet alone buy a brand new car to be able to fall under the low permit charge
bracket? Secondly Newham sanctioned the restriction zone through Browning Road. How exactly has
that made matters better. It’s made it far worse with Romford Road being extremely congested during
peak hours. Thirdly Newham promote residents the use of electric cars. As I mention in the above
residents are of low income so how is one to afford one? Not only that, how does one charge there
electric vehicle if they have street parking and cannot be guaranteed a space outside their home. If

                                                   17
one has an electric car parked across the road or half way up the road. How exactly do they charge
there vehicle? Run extension leads and cause a trip hazard? Would be interesting to know your
solutions to this.

To be putting this into place at such difficult times whilst the world tackles with Covid 19 it is a shame
that Newham would like to impose this during this difficult time. Whilst many are struggling due to
being on Furlough or redundant due to pandemic putting more financial strain and effect on wellbeing
to those less fortunate.

Officer Response: The council has considered the concerns that may arise from the proposed
introduction of emissions‐based parking permit charges when the economy is suffering due to the
outbreak of Covid‐19 and has agreed to defer the introduction of the new charging regime until
January 2020, so as to allow for a period of economic recovery and for residents to have adequate
advance notice of the new charges coming into effect.

It is therefore recommended the objections be over‐ruled and the introduction of emissions based
parking permit charges be progressed.

Ashikur Rahman ‐ I am writing to represent my objections to the proposed Statutory Parking
Consultation on permit parking charges.
It is apparent that you are not listening to the residents who have voted against the proposed residents
permit charges on the informal online survey which closed on March 20th 2020.
Furthermore the survey was conducted online during the early stages of the pandemic and was not
highly publicised. The survey started on the 2nd March 2020 and was due to close on 22nd March
2020. Newham council have acted extremely immorally and unethically, many residents would have
been understandably distressed during the early stages of the pandemic therefore this survey should
have been suspended. Nevertheless as the results of this 'informal' survey have been included in this
statutory consultation you are obliged to act upon the findings from them rather than discount the
findings due to a low response.
As I stated above residents understandably had other pressing issues during the pandemic to address.
Unfortunately, the Council doesn't have any transparency which is evident within this statutory
consultation and the FAQ's.
If residents are encouraged to leave their cars at home for short journeys then why charge them for
parking their cars at home?
If residents are being encouraged to move to less polluting cars, then why not offer to install charging
points in a street where every household purchases an electric car?
In the unprecedented times, when many residents have lost their jobs due to the COVID‐19, with even
more redundancies imminent it seems unjustified to implement such a charging structure given the
demographics of the borough.
I hope you will take the above into account and abandon this consultation.

Graham Teale ‐ I live in the Borough and vehemently object to the implementation of this charge.
The grounds for such an objection are:

    1. Lack on direct consultation with the residents of the Borough

    2. A vast majority will be unaware of such a change.

    3. Parking permits were sold to residents on the grounds that it would always be free for the
       first vehicle.

    4. Live in an area that was never impacted by non‐residential parking

    5. The cost to residents in the time of COVID crisis is unacceptable

    6. The cost to residents to change their vehicles to the free option is prohibitive at the moment,
       with the uncertainty on the economy.

    7. No available charging points near to my home, the nearest being in a supermarket car park.

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